Let's step back and review my April 24 comment. Prompted by one of our astute Threads readers, I reviewed the regulatory language. There is nothing there that prohibits combining mortgage statements with other statements. In fact, there is language that says nothing in section 1026.41 "combining disclosures required by this subpart, unless such prohibition is expressly set forth in this subpart, or other applicable law."
I just didn't think it was feasible to combine a mortgage statement complying with 1026.41 with other statements. But I've been amazed at the ingenuity of many banks and service providers who have crafted well-designed combinations of otherwise disparate things, so I really have to soften my "for certain" comment, and suggest that the bank may have to use separate statements for mortgages, but may find a way to effectively combine them without going astray of the 1026.41 standards.
Thanks, Ben.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8